"To the extent that the final rule is similar to the proposed rule from October of last year, the Financial Stability Oversight Council seems properly focused on the type of institutions which experienced the most difficulty during the financial crisis. As the FSOC moves into the process of designating those ‘systemically important financial institutions’, we believe the criteria approved by the Council today will reaffirm the argument made by NAMIC and others since the crisis began that traditional property/casualty insurers pose no broader threat to our economic stability."